Germany - Arm’s Length Nature of a Transfer Price as the Decisive Criterion for Compliance with the Arm’s Length Principle (Not Only) in Treaty Cases
- U. Andresen; D. Kerenyi
- International Transfer Pricing Journal, 2013 (Volume 20), No 3
- 6 May 2013
A recent decision of the Federal Tax Court concerned the blocking effect of article 9 of the OECD Model and its derivatives over the special conditions developed in prior jurisprudence of the Federal Tax Court.